PGFN/MF Ordinance No. 721, published on April 7, 2025, regulates the transaction in the collection of judicialized credits of high economic impact under the Comprehensive Transaction Program (PTI), established by Normative Ordinance MF No. 1,383/2024. This measure aims to enable negotiated solutions for significant tax debts under judicial discussion, based on the Reasonable Recovery Potential of Judicialized Credit (PRJ), as defined by the National Treasury Attorney General’s Office (PGFN).
Criteria for Inclusion in the Transaction:
Eligible for transaction are credits that, as of the publication date of the Ordinance (i.e., April 7, 2025), are:
- Registered as federal debt and subject to anti-enforcement judicial action;
- Registered as federal debt equal to or exceeding BRL 50 million with enforceability suspended by judicial decision or secured by attachment, insurance, or surety bond; and
- Accessory registrations of lower value, provided they are linked to the same judicial process.
Transaction Benefits:
Granted benefits may include:
- Discount of up to 65% on the total debt amount (excluding principal);
- Installment payment in up to 120 months, or up to 60 months for social contributions;
- Payment scaling with or without down payment, use of federal precatory payments or liquid and certain credits recognized by court to amortize debts; and/or
- Conversion of judicial deposits into definitive payment and possible flexibility or replacement of guarantees.
Adhesion Procedures:
Adhesion will be available from April 7 to July 31, 2025, exclusively through the REGULARIZE portal. The proposal can be submitted by the taxpayer or by the PGFN, with the Attorney General’s Office responsible for analyzing the specific case to define applicable benefits according to the PRJ.
Required Documentation:
To request the transaction, the taxpayer must submit:
- Accounting documents proving the recognized liability;
- Report on the procedural status of the related legal actions; and
- Term of waiver of the right underlying the legal action, including appeals and collective actions.
Analysis Criteria:
PGFN will consider factors such as:
- Legal risk of the issue under discussion;
- Degree of controversy;
- Estimated time for judicial credit recovery; and
- Costs associated with collection.
The PRJ is a technical and confidential indicator used to guide the structuring of the transaction proposal.
Agreement Formalization:
The agreement will depend on mutual consent and, in cases of debts exceeding BRL 500 million, will require approval from the higher instance of the PGFN.
Contact our office and schedule a consultation. We are available to protect your rights.
Franco Advogados
